May v. Commissioner
United States Tax Court
Petitioner claimed as an itemized interest deduction an amount paid to respondent for failure to pay timely her proper tax liabilities. Sec. 6651(a)(2). Held, the above amount does not represent interest and does not constitute an allowable deduction.
1Opinion of the Court
OPINION
Sterrett, Judge:
The respondent determined a deficiency in petitioner’s Federal income tax for the calendar year 1972 in the amount of $113.72. One other adjustment not being in issue, the sole remaining issue is whether the amount paid by petitioner to respondent pursuant to section 6651(a)(2) of the Internal Revenue Code of 19541 is allowable as a deduction.
All of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.
Petitioner Frances J. May is an individual who resided in…
2Cases cited2 opinions
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Reuter v. CommissionerUnited States Tax Court · 1961
3Cited by15 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Uhlenbrock v. CommissionerUnited States Tax Court · 1977
- Tucker v. CommissionerUnited States Tax Court · 1978
- Patton v. CommissionerUnited States Tax Court · 1978
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